Intermediate Archiving: means the movement of Personal Data that is still of administrative interest to the Publisher, (such as in the event of litigation and/or in the event of aThis archive is an intermediary step before the disposal of the Personal Data. The archive is a separate database, logically or physically separated and whose access is restricted. This archive is an intermediate step before the deletion of the Personal Data concerned or their anonymization;
Regulation on Personal Data: Refers to the Law n°78-17 of January 6, 1978 relating to data processing, files and freedoms, amended by the Law n°2018-493 of June 20, 2018 relating to the protection of personal data, in application of the EU Regulation of April 27, 2016 published in the Official Journal of theEuropean Union on May 4, 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data (known as "RGPD" for General Data Protection Regulation) ;
Terminal(s): refers to the hardware equipment (computer, tablet, smartphone, telephone, etc.) used by the Internet user to consult or view the Site and/or any other digital medium published by a third party;
Internet user: refers to all Internet users, visitors to the Site.
3. The legal bases of the processing carried out by the Editor
The use of the Website is necessarily governed by a contractual relationship between the User and the Editor, serving in particular as a legal basis for the collection and processing of the User's Personal Data by the Editor for the proper functioning of the Website and the realization of the associated services.
The processing of Personal Data may also be necessary to comply with a legal obligation to which the Editor is subject.
The processing of the Personal Data of the Internet User may finally be necessary for the purposes of the legitimate interests pursued by the Editor or by a third party, unless the interests or the interests of the third party prevail. unless the interests or the fundamental rights and freedoms of the Internet User prevail and require the protection of Personal Data, in particular when the Internet User is a child.
The processing of Personal Data of the Internet User strictly necessary for fraud prevention purposes constitute for example a legitimate interest of the Editor.
In the event of processing based on the legitimate interest of the Editor or a third party, the Editor ensures that the processing in question is necessary to achieve its legitimate interest and assesses the extent to which the processing is necessary to achieve its legitimate interest.alization of its legitimate interest and assesses the consequences of this processing on the Internet user, in particular by taking into account the nature of the Personal Data processed, and the way they are processed.
4. The purposes of the processing carried out by the Editor
The Personal Data of the Internet user are necessary to allow him to access the Site, its use and its improvement, and to allow the Editor to provide the possible services detailed on the Site.
The operations exposed hereafter are not used to lead to the establishment of profiles likely to reveal so-called sensitive Personal Data such asThe operations exposed hereafter do not serve to lead to the establishment of profiles likely to reveal Personal Data known as sensitive such as racial or ethnic origins, philosophical, political, trade-union, religious opinions, sexual life or health and do not serve either to produce automated decisions on behalf of the Editor.
5. Storage of Personal Data
The Site is hosted by the company AWS, whose contact information is available by clicking here Legal Notice.
All precautions have been taken to store the Personal Data of Internet users in a secure environment and prevent them from being distorted, damaged or accessed by unauthorized third parties. The information transmitted by the Internet user will never be transmitted to third parties for commercial purposes, nor sold or exchanged.
6. The collection of Personal Data on the Site
The Editor collects the Personal Data that the Internet user informs spontaneously on the Site.
These Personal Data are kept by the Editor for a duration of two (2) years, in active base, as from their communication from the Site.
The Personal Data concerned are then kept in Intermediate Storage for an additional period of three (3) years in accordance with the common limitation period.
If necessary, the Publisher may decide to keep these Personal Data for a longer period of time in Intermediate Storage, in order to comply with a legal obligation (for example, the article L.123-22 of the French Commercial Code which provides that "Accounting documents and supporting documents are kept for ten years") or to allow the Publisher to establish the proof of a right or a contract.
Only the Personal Data designated on the Site as mandatory are essential to benefit from the services provided by the Site.
7. Recipients or categories of recipients of Personal Data
The Personal Data of the Internet User are communicated to the subcontractors of the Editor, namely :
AYS (klixi), a simplified joint stock company with a capital of 50 000 Euros, whose head office is located at 18, rue de Londres 75009 Paris - France, registered in the Paris Trade and Companies Register under the number 535 351 472 - https://www.klixi.io/fr/mentions-legales
Functionality: Developer and management and administration tool of the Site by the Publisher
Data transfer outside the EU and specific guarantees: No
Amazon Web Services LLC (AWS) P.O. Box 81226 Seattle, WA 98108-1226 - https://aws.amazon.com
Functionality: Site Hosting
Data transfer outside the EU and specific guarantees: Yes - Privacy Shield
If applicable - Stripe Payments Europe, Ltd 1 Grand Canal Street Lower, Grand Canal Dock, Dublin, Ireland - https://www.stripe.com/fr
Functionality: Payment module
Data transfer outside the EU and specific safeguards: No
If applicable - Twilio Inc. 375 Beale Street, Suite 300 San Francisco, CA 94105 - https://www.twilio.com
Functionality: To allow the Editor to exchange with the Internet user from a chat module on the Site
If applicable - Mandrill - The Rocket Science Group, LLC 675 Ponce de Leon Ave NE Suite 5000 Atlanta, GA 30308 USA - https://mailchimp.com/
Functionality: To allow the Editor to send email campaigns to Internet users who have provided their email address
If applicable - TextMagic - TEXTMAGIC LTD, Salisbury House Station Road Cambridge CB1 2LA United Kingdom, VAT Reg No: GB851556810, Company No: 05286521 - https://www.textmagic.com
Functionality: To allow the Editor to send SMS campaigns to Internet users who have provided their telephone number
8. Internet users' rights
In accordance with the Personal Data Regulations, the Internet User may, at any time, benefit from the following Specific Rights of/to :
* access (Article 39 of Law No. 78-17 of January 6, 1978 relating to computers, files and freedoms),
* rectification (article 40 of the Law n° 78-17 of January 6, 1978 relating to data processing, files and freedoms)
* deletion (Article 40 of Law No. 78-17 of January 6, 1978 relating to data, files and freedoms),
* limitation of a treatment (Article 40 of the Law n° 78-17 of January 6, 1978 relating to data processing, files and freedoms)
* portability (Article 20 of the GDPR),
* opposition (article 38 of the Law n° 78-17 of January 6, 1978 relating to data processing, files and freedoms),
* post-mortem directives (article 40-1 of the Law n°78-17 of January 6, 1978 relating to data processing, files and freedoms),
8.1 Access rights
The Internet user has the possibility to obtain from the Editor the confirmation that the Personal Data concerning him are or are not processed and, when they are, the access to the said Personal Data as well as the following information:
* the purposes of the processing;
* the categories of Personal Data;
* the recipients or categories of recipients to whom the Personal Data have been or will be communicated;
* where possible, the period for which the Personal Data will be kept or, where this is not possible, the criteria used to determine this period
* the existence of the right to request from the Publisher the rectification or deletion of Personal Data, or a limitation of the processing of Personal Data, or the right to object to such processing;
* the right to file a complaint with the CNIL;
* when the Personal Data are not collected from the Internet user, any available information about their source;
* the existence of automated decision-making, including profiling, and, at least in such cases, useful information concerning the underlying logic, as well as the importance and the expected consequences of this processing for the Internet user;
Where Personal Data is transferred to a third country or to an international organization, the Internet User has the right to be informed of the appropriate safeguards with respect to such transfer.
The Publisher shall provide a copy of the Personal Data being processed.
The Publisher may charge a reasonable fee based on administrative costs for any additional copies requested by the User.
Where the Internet User submits a request electronically, the information will be provided in a commonly used electronic format, unless the Internet User requests otherwise.
The Internet User's right to obtain a copy of his or her Personal Data shall not infringe upon the rights and freedoms of others.
8.2 Rights of rectification
The Internet User has the possibility to obtain from the Editor, as soon as possible, the rectification of Personal Data concerning him/her which are inaccurate. He also has the possibility to obtain that the incomplete Personal Data be completed, including by providing an additional declaration.
8.3 Right to erasure
The User has the right to obtain from the Publisher the deletion, as soon as possible, of Personal Data concerning him when one of the following reasons applies:
* The Personal Data are no longer necessary for the purposes for which they were collected or otherwise processed by the Editor;
* The Internet User has withdrawn his consent for the processing of this Personal Data and there is no other legal basis for the processing;
* The Internet User exercises his/her right to object under the conditions recalled below and there is no compelling legitimate reason for the processing;
* The Personal Data have been processed unlawfully;
* The Personal Data must be deleted to comply with a legal obligation;
* The Personal Data has been collected from a child.
8.4 Rights to limitation
The User has the possibility to obtain from the Editor the limitation of the processing of his Personal Data when one of the following reasons applies:
* The Editor verifies the accuracy of the Personal Data following the Internet User's challenge of the accuracy of the Personal Data,
* The processing is unlawful and the User objects to the deletion of the Personal Data and demands instead the limitation of their use;
* The Editor no longer needs the Personal Data for the purposes of processing but they are still necessary to the Internet user for the establishment, exercise or defense of legal rights;
* The User has objected to the processing under the conditions recalled below and the Editor verifies whether the legitimate reasons pursued prevail over the alleged reasons.
8.5 Right to Data portability
The Internet User has the possibility to receive from the Editor the Personal Data concerning him, in a structured, commonly used and machine-readable format when:
* the processing of Personal Data is based on consent, or on a contract and
* the processing is carried out using automated processes.
When the Internet user exercises his right to portability, he has the right to have the Personal Data transmitted directly by the Publisher to another controller that he will designate when technically possible.
The right to portability of Personal Data of the Internet User must not infringe the rights and freedoms of others.
8.6 Right of opposition
The Internet User may object at any time, for reasons relating to his particular situation, to the processing of Personal Data concerning him based on the legitimate interests of the Publisher. The Publisher will then no longer process the Personal Data, unless it can demonstrate that there are compelling and legitimate grounds for the processing that override the interests and rights of the User.The Editor will then no longer process the Personal Data, unless it can demonstrate that there are compelling and legitimate reasons for the processing that override the interests and rights and freedoms of the Internet user, or may retain them for the establishment, exercise or defense of legal claims.
8.7 Post-mortem directives
The Internet User has the possibility to communicate to the Editor directives relating to the conservation, the deletion and the communication of his Personal Data after his death, which directives shall be communicated to the Editor.These directives can also be registered with a "certified digital trustworthy third party". These directives, or a sort of "digital will", may designate a person in charge of their execution; failing that, the Internet user's heirs will be designated.
In the absence of any directive, the Internet User's heirs may contact the Publisher in order to :
* access the processing of Personal Data allowing "the organization and settlement of the deceased's estate" ;
* receive communication of "digital assets" or "data similar to family memories, which can be transmitted to heirs";
* to proceed with the closure of the Internet user's account on the Site if necessary and to oppose the continuation of the processing of his/her Personal Data.
In any case, the Internet User has the possibility to indicate to the Editor, at any time, that he does not wish, in case of death, that his Personal Data be communicated to a third party.
9. Exercise of the Specific Rights of Internet Users
These rights can be exercised, at any time, with the Editor whose coordinates are indicated in the legal notice.
In order to assert its rights under the conditions mentioned above and in the event that the Editor has doubts about the author of the request, the Editor may ask the latter to prove his identity by mentioning his name, first name, e-mail address and to accompany his request with a copy of a valid identity document.
A reply will be sent to the Internet user within a maximum of one (1) month following the date of receipt of the request.
If necessary, this period may be extended by two (2) months by the Publisher, who will notify the Internet User, taking into account the complexity and/or number of requests.
In case of request from the User for deletion of his Personal Data and/or in case of exercise of his right to request the deletion of his Personal Data, the Publisher may however keep them in the form ofIntermediary Archiving, for the time necessary to comply with its legal obligations, or for evidentiary purposes during the applicable limitation period.
Hôtel Nice Azur Riviera - 19 Rue Assalit - 06000 Nice, France
firstname.lastname@example.org - +33 4 22 53 02 25